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Stonehill Vs Diokno

The Supreme Court ruled that the petitioners, who were corporate officers, could not validly challenge search warrants issued against the corporations. The Court held that corporations have separate legal personalities from their officers and shareholders. Only the corporations themselves could object to seizures of documents from their offices, not the petitioners in their individual capacities. Therefore, the petitioners could not prevent evidence seized from the corporate offices from being used against them.

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311 views1 page

Stonehill Vs Diokno

The Supreme Court ruled that the petitioners, who were corporate officers, could not validly challenge search warrants issued against the corporations. The Court held that corporations have separate legal personalities from their officers and shareholders. Only the corporations themselves could object to seizures of documents from their offices, not the petitioners in their individual capacities. Therefore, the petitioners could not prevent evidence seized from the corporate offices from being used against them.

Uploaded by

Steiner
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Stonehill vs Diokno

20 SCRA 383
G.R. No. L-19550             June 19, 1967

Facts:
Respondents herein secured a total of 42 search warrants against petitioners herein and the
corporations of which they were officers, to search “books of accounts, financial records,
portfolios, and other documents and papers showing all business transactions including
disbursements receipts, balance sheets and profit and loss statements and Bobbins,” as “the
subject of the offense; stolen or embezzled and proceeds or fruits of the offense,” or “used or
intended to be used as the means of committing the offense,” which is described in the
applications adverted to above as “violation of Central Bank Laws, Tariff and Customs Laws,
Internal Revenue (Code) and the Revised Penal Code.”
The petitioner contended that the search warrants are null and void as their issuance violated
the Constitution and the Rules of Court for being general warrants.
The documents, papers, and things seized under the alleged authority of the warrants in
question may be split into two (2) major groups, namely: (a) those found and seized in the
offices of the aforementioned corporations, and (b) those found and seized in the residences of
petitioners herein.
Issue: Whether petitioners can validly assail the search warrant against the corporation.
Held: No.
As regards the first group, we hold that petitioners herein have no cause of action to assail the
legality of the contested warrants and of the seizures made in pursuance thereof, for the simple
reason that said corporations have their respective personalities, separate and distinct from the
personality of herein petitioners, regardless of the amount of shares of stock or of the interest
of each of them in said corporations, and whatever the offices they hold therein may
be. Indeed, it is well settled that the legality of a seizure can be contested only by the party
whose rights have been impaired thereby, and that the objection to an unlawful search and
seizure is purely personal and cannot be availed of by third parties. Consequently, petitioners
herein may not validly object to the use in evidence against them of the documents, papers and
things seized from the offices and premises of the corporations adverted to above, since the
right to object to the admission of said papers in evidence belongs exclusively to the
corporations, to whom the seized effects belong, and may not be invoked by the corporate
officers in proceedings against them in their individual capacity. 

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